2013

OVDI: Is the IRS Playing Fair?
Listen A Message From Uncle Sam to Taxpayers Who Have Undisclosed Foreign Bank Accounts: The Clock Is Ticking Since 2009, the IRS has offered taxpayers with undisclosed foreign financial accounts the opportunity to “come clean” under its Offshore Voluntary Disclosure Initiative (OVDI).  According to the IRS, more than 38,000 U.S. taxpayers have entered the program.  …
UNDERSTANDING THE SOURCE OF INTEREST RULE WITHOUT SUFFERING A MIGRAINE
Listen As a general rule, interest paid by individuals, partnerships, and trusts takes its source from their place of residence.  A natural corollary to this rule is that interest paid by individuals, partnerships, and trusts that are “residents” of the United States has U.S. source. This source rule has consequences that both borrowers and lenders …
IS THAT WORKER AN EMPLOYEE? QUESTIONS AND ANSWERS ON WORKER CLASSIFICATION
Listen If you own or manage a business that uses independent contractors, you need to know when you can or cannot treat a worker as an independent contractor.  This article answers some of the common questions about worker classification. INTRODUCTION Misclassification of employees as independent contractors is now a common phrase uttered by state and …
LIFTING THE VEIL ON THE BLACK MARKET PESO EXCHANGE — PART II: THE MECHANICS
Listen The BMPE consists of two interrelated activities.  One occurs in Colombia: the purchase of accumulated drug dollars in America.  And the other occurs in the United States: the actual delivery of drug dollars to the money exchanger’s associate in the United States. 1.      Purchase of Dollars in Colombia The BMPE process begins when the …